In Vaden v. Discover Bank (2009) 129 S.Ct. 1262, the Court held that under 9 USC 4, to determine whether a federal court has jurisdiction over a petition to compel arbitration, the court should “look through” the arbitration issue and determine whether the court would have jurisdiction of the underlying dispute in the absence of an arbitration agreement.  This decision holds that the exceptional “look through” approach adopted in Vaden was dictated by section 4’s unique language.  The same cannot be said of 9 USC 9-11, which govern petitions to confirm or vacate arbitration awards and lack section 4’s wording.  Hence, a federal court cannot follow the “look through” approach to exercise jurisdiction over those types of petitions.  Instead, federal jurisdiction over a petition to confirm or vacate an arbitration award is governed by the petition’s allegations.  Under that approach it will be difficult to base jurisdiction on a federal question since even if the underlying dispute raised federal claims, the petition to confirm or vacate most likely will raise only state law issues regarding the efficacy of the arbitration agreement and award.